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Income Tax - Highlights / Catch Notes

Home Highlights July 2019 Year 2019 This

Compensation received on termination of network participation ...

Income Tax

July 10, 2019

Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India

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